In the Interest of M.A. Jr and N.A., Children v. the State of Texas
CourtTexas Court of Appeals, 11th District (Eastland)
Date FiledAugust 13, 2026
Docket11-26-00054-CV
StatusPublished
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Full Opinion
Opinion filed August 13, 2026
In The
Eleventh Court of Appeals
__________
No. 11-26-00054-CV
__________
IN THE INTEREST OF M.A. JR. AND N.A., CHILDREN
On Appeal from the 326th District Court
Taylor County, Texas
Trial Court Cause No. 11684-CX
OPINION
It has been said that because the termination of one’s parental rights
permanently extinguishes fundamental rights of a constitutional dimension, it is thus
akin to the “‘death penalty’ of civil cases.” See In re R.J.G., 681 S.W.3d 370, 373,
381 (Tex. 2023) (quoting In re D.T., 625 S.W.3d 62, 69 (Tex. 2021)). In this
accelerated appeal, the mother and the father of M.A. Jr. and N.A,1 challenge the
trial court’s order that terminated their rights to them.
1
To protect the identities of the children and the children’s family members, we use pseudonyms
or initials to refer to them. See TEX. R. APP. P. 9.8(b).
In two issues, the mother challenges the sufficiency of the evidence to support
the trial court’s findings that: (1) termination of her parental rights is in the children’s
best interest; and (2) a continuing danger exists that prevents the return of the
children to her, and the Texas Department of Family and Protective Services (the
Department) made reasonable efforts to return the children to her prior to the
commencement of the final hearing; she further raises a challenge to the specificity
of the trial court’s order regarding those efforts. See TEX. FAM. CODE ANN.
§ 161.001(b)(2), (f), (g) (West Supp. 2025).
The father presents three issues in which he challenges the sufficiency of the
evidence to support the trial court’s findings that: (1) the Department made
reasonable efforts to return the children to him prior to the commencement of the
final hearing; and like the mother, he also raises a challenge to the specificity of the
trial court’s order regarding those efforts; (2) he endangered the children under
subsections (D) and (E) of the Family Code; and (3) termination of his parental rights
is in the children’s best interest. See id. § 161.001(b)(1)(D), (E), (b)(2), (f).
For the reasons discussed below, we affirm in part, and we reverse and remand
in part.
I. Termination Findings and Standards
As the Texas Supreme Court recently stated, “[s]undering ties between parent
and child ‘can never be justified without the most solid and substantial reasons.’” In
re J.Z.A., No. 25-0787, 2026 WL 1838580, at *1 (Tex. June 26, 2026) (quoting
Wiley v. Spratlan, 543 S.W.2d 349, 352 (Tex. 1976)). Because of this, to terminate
one’s parental rights, the Department must “clear[] a high bar.” In re K.N., No. 24-
0881, 2026 WL 1614378, at *6 (Tex. June 5, 2026); see also In re H.S., No. 24-
0307, 2026 WL 1614496, at *8–9 (Tex. June 5, 2026) (re-emphasizing that
terminating parental rights “‘is always the last resort’ . . . permissible to protect
children from serious harm . . . [and] may be exercised only in the absence of other
2
legitimate options.” (quoting D.V. v. Tex. Dep’t of Fam. & Protective Servs., 722
S.W.3d 854, 861 (Tex. 2025))).
The controlling standard requires that, to support termination, the Department
present clear and convincing evidence that (1) the parent has committed one of the
acts listed in Section 161.001(b)(1), and (2) termination is in the best interest of the
child. See FAM. § 161.001(b). Clear and convincing evidence is “the measure or
degree of proof that will produce in the mind of the trier of fact a firm belief or
conviction as to the truth of the allegations sought to be established.” FAM.
§ 101.007 (West 2019). This heightened standard “is unforgiving” and “the
government may not sever the legal ties between parents and children without
clearing [this] high bar.” K.N., 2026 WL 1614378, at *6–7. In that regard, “[a] lack
of evidence does not constitute clear and convincing evidence.” See In re E.N.C.,
384 S.W.3d 796, 808 (Tex. 2012); In re M.A.J., 612 S.W.3d 398, 410 (Tex. App.—
Houston [1st Dist.] 2020, pet. denied).
In this case, the trial court found that clear and convincing evidence
established that each parent: (1) knowingly placed or knowingly allowed the
children to remain in conditions or surroundings which endangered the physical or
emotional well-being of the children; and (2) engaged in conduct or knowingly
placed the children with persons who engaged in conduct which endangered the
physical or emotional well-being of the children. See id. § 161.001(b)(1)(D), (E).
The trial court further found that termination of each parent’s parental rights is in the
children’s best interest. See id. § 161.001(b)(2).
In reviewing a legal sufficiency challenge, we must decide whether “a
reasonable trier of fact could have formed a firm belief or conviction that its finding
was true.” In re J.W., 645 S.W.3d 726, 741 (Tex. 2022). Cognizant of our deference
to the factfinder, “we look at all the evidence in the light most favorable to the
finding, assume that the factfinder resolved disputed facts in favor of its finding if a
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reasonable factfinder could do so, and disregard all evidence that a reasonable
factfinder could have disbelieved or found to have been incredible.” Id. (internal
quotation marks omitted). “However, we may not disregard ‘undisputed facts that
do not support the finding,’” and that the factfinder is “the sole arbiter of the
witnesses’ credibility and demeanor.” Id. (first quoting In re J.F.C., 96 S.W.3d 256,
266 (Tex. 2002); and then quoting In re J.F.-G., 627 S.W.3d 304, 312 (Tex. 2021)).
As such, when considering the credibility of the evidence presented, we may not
substitute our judgment for that of the factfinder. J.F.-G., 627 S.W.3d at 316.
In assessing whether the evidence is factually sufficient to support the finding,
we weigh the disputed evidence that is contrary to the finding against all evidence
that favors the finding. In re A.C., 560 S.W.3d 624, 631 (Tex. 2018). We give due
deference to the finding, and determine whether, based on the entire record, a
factfinder could have reasonably formed a firm belief or conviction about the truth
of the allegations asserted against the parent. In re J.O.A., 283 S.W.3d 336, 345
(Tex. 2009); In re C.H., 89 S.W.3d 17, 25–26 (Tex. 2002); In re L.C.C., 667 S.W.3d
510, 512 (Tex. App.—Eastland 2023, pet. denied).
With respect to the best interest of the child, no unique set of factors need be
proved. L.C.C., 667 S.W.3d at 513; In re C.J.O., 325 S.W.3d 261, 266 (Tex. App.—
Eastland 2010, pet. denied). Further, the best interest determination does not restrict
the proof to any specific factor or factors. In re J.S., 687 S.W.3d 541, 547 (Tex.
App.—Eastland 2024, no pet.). Nevertheless, courts may use and rely on the non-
exhaustive Holley factors to shape their analysis. Holley v. Adams, 544 S.W.2d 367,
371–72 (Tex. 1976). These include, but are not limited to: (1) the desires of the
child; (2) the emotional and physical needs of the child now and in the future; (3) the
emotional and physical danger to the child now and in the future; (4) the parental
abilities of the individuals seeking custody; (5) the programs available to assist these
individuals to promote the best interest of the child; (6) the plans for the child by
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these individuals or by the agency or person seeking custody; (7) the stability of the
home or proposed placement; (8) the acts or omissions of the parent that may
indicate the existing parent-child relationship is not a proper one; and (9) any excuse
offered for the acts or omissions of the parent. Id.
To support a best interest finding, the Department is not required to prove
each Holley factor; in some circumstances, evidence of only one factor will suffice.
C.H., 89 S.W.3d at 27; In re D.M., 452 S.W.3d 462, 473 (Tex. App.—San Antonio
2014, no pet.). Additionally, the same evidence that proves one or more statutory
grounds for termination may also constitute sufficient, probative evidence
illustrating that termination is in the child’s best interest. C.H., 89 S.W.3d at 28;
J.S., 687 S.W.3d at 547–48; C.J.O., 325 S.W.3d at 266; see also H.S., 2026 WL
1614496, at *9 (Although the heightened standard of appellate review applies to both
the grounds for termination and the best interest analysis, evidence that supports a
finding under subsection (b)(1) “may also be, and indeed often is, relevant to best
interest under [subsection] (b)(2).”).
The absence of evidence of some Holley considerations does not preclude the
factfinder from reasonably inferring or forming a strong conviction or belief that
termination is in the child’s best interest, particularly if the evidence indicates that
the parent-child relationship and the parent’s conduct has endangered the safety and
well-being of the child. C.H., 89 S.W.3d at 27. This is so because the best interest
analysis evaluates the best interest of the child, not the parent. J.S., 687 S.W.3d at
548; In re E.C.R., 638 S.W.3d 755, 767 (Tex. App.—Amarillo 2021, pet. denied)
(citing In re B.C.S., 479 S.W.3d 918, 927 (Tex. App.—El Paso 2015, no pet.)).
In this regard, the factfinder may measure a parent’s future conduct by his or
her past conduct in determining whether termination of a parent’s parental rights is
in the child’s best interest. J.S., 687 S.W.3d at 548; In re Z.R.M., 665 S.W.3d 825,
829 (Tex. App.—San Antonio 2023, pet. denied); In re D.S., 333 S.W.3d 379, 384
5
(Tex. App.—Amarillo 2011, no pet.). The factfinder may infer that a parent’s past
conduct that endangered the safety and well-being of the child may recur in the
future if the child is returned to the possession of the parent. J.S., 687 S.W.3d at
548; In re J.D., 436 S.W.3d 105, 118 (Tex. App.—Houston [14th Dist.] 2014, no
pet.); May v. May, 829 S.W.2d 373, 377 (Tex. App.—Corpus Christi–Edinburg
1992, writ denied). Moreover, the factfinder may infer from a parent’s past inability
to meet the child’s physical and emotional needs an inability or unwillingness by the
parent to meet the child’s physical and emotional needs in the future. J.S., 687
S.W.3d at 548; J.D., 436 S.W.3d at 118; see also In re A.S., No. 11-16-00293-CV,
2017 WL 1275614, at *3 (Tex. App.—Eastland Mar. 31, 2017, no pet.) (mem. op.).
II. Background and the Evidence Presented at Trial
The Department initiated contact with the mother and father in August 2024
because of the father’s reported drug use and the mother’s mental health issues—
specifically, that the mother had attempted suicide the previous month and told the
father that she and the children were going to die. The parents had separated
because, according to the mother, the father “was leaving [her] for [her] friend.” At
that time, M.A. Jr. was almost nine, and N.A. was almost seven.
When the Department Investigator, Christina Burrow, spoke to the father,
“[h]e did not feel [the mother] was safe at the time due to her mental health,” but he
suggested that the mother’s text messages “were taken out of context.” The father
clarified that the mother said, “she and the children may die because there wasn’t
food in the home, but he believed there to be food in the home.” The father also
disclosed that he used cocaine in July 2024. Burrow then contacted the mother, who
confirmed that she had attempted suicide, continued to experience suicidal ideations,
and used marihuana daily.
Both parents refused to sign a safety plan. Nevertheless, the Department
placed the children with the father based on his assurance that he would prohibit the
6
children’s unsupervised contact with the mother. The mother successfully
completed the inpatient mental health program at Oceans Behavioral Hospital in
Abilene and was discharged on September 13, 2024. According to Burrow, the
mother was taking her prescribed medications, and her mental health appeared to be
more stable. The mother began living at the Noah Project, a shelter for victims of
family violence, sexual assault, and human trafficking, which Burrow believed to be
a safe and stable environment. Burrow learned on September 16 that the children
were staying with the mother at the Noah Project—evidently, the father had
relinquished them to her care because he was using methamphetamine.
Burrow then petitioned the trial court to order the mother and father to
participate in family-based safety services 2 to avoid the children’s removal, which
included drug testing. In November 2024, the children tested negative for all illegal
substances, but the mother tested positive for methamphetamine, amphetamine, and
marihuana. The father’s urinalysis (UA) was negative for illegal substances, but his
hair follicle drug test was positive for methamphetamine and amphetamine. When
the Department again attempted to implement a safety plan, the parents could not
provide the name of an approved adult to serve as a safety monitor or Parental Child
Safety Placement. See FAM. §§ 264.901(2), .902. On November 19, 2024, five days
before N.A.’s seventh birthday, the Department was granted temporary managing
conservatorship of the children. The children spent two days in a shelter before
moving to a kinship placement.
The Department created family plans of service for each parent, which the
trial court amended and adopted as orders of the court on March 19, 2025. Both
2
“Family-based safety services are protective services provided to a family whose children are not
in the conservatorship of the Department.” 40 TEX. ADMIN. CODE pt. 19 ch. 700 subch. G div. 2 § 710
(2021). The Department’s Child Protective Services Division provides family-based safety services to
families and children “to: (1) protect the children from abuse and neglect; (2) help the family reduce the
risk of future abuse or neglect; and (3) prevent the removal of the children from their home.” Id.; see also
FAM. §§ 262.402–.410 (authorizing and implementing the Family Preservation Services Pilot Program).
7
parents engaged in counseling and submitted to drug testing. The father tested
positive for methamphetamine and amphetamine in January and February 2025.
However, in March and April 2025, he submitted UAs that were negative for all
illegal substances. The mother tested positive for marihuana, methamphetamine,
cocaine, and alcohol in March 2025, and positive for benzodiazepines and
marihuana in May 2025.
The Department sent a referral for the father’s first substance abuse
assessment in April 2025, which he attended on May 1. The following week, he
began participating in outpatient substance abuse treatment. The father relapsed
following this treatment and tested positive for cocaine in June and August 2025. In
July, recognizing that he needed a higher level of care, the father contacted the newly
assigned Department caseworker, Ryan Riggs, to request inpatient treatment.
Riggs did not send a substance abuse assessment referral for the father for
almost two weeks. Then, because of scheduling difficulties not caused by the father,
Riggs had to send another referral for the father, who was ultimately assessed in
September. On November 1, after spending months on a waitlist, the father began a
forty-three-day residential treatment program, which he successfully completed on
December 9, 2025. Although the father’s January 2026 hair follicle drug test was
positive for cocaine, his UAs were negative in December 2025, and January and
February 2026. The father contacted Riggs within a week of his discharge to resume
parent-child visitations, but his first scheduled visit after the completion of his
inpatient treatment did not occur until mid-January, a month after he had asked to
see his children.
Meanwhile, the mother successfully completed her parenting course and
inpatient substance abuse treatment in July 2025 at Serenity House in Abilene. She
attended weekly supervised parent-child visitation and counseling with Stacy
Reynolds, a licensed chemical dependency counselor whom the mother contacted as
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“a self-referral,” without assistance from the Department. Since her discharge from
Serenity House, the mother also met “[a]t least once or twice a week” with Allison
Vasquez, her case manager and mental health professional at Betty Hardwick, to
monitor her mental health and manage her medications.
After completing residential treatment, the mother’s UAs in July, August,
September, and November 2025 were negative for all illegal substances, and the
levels of illegal substances from her hair follicle drug tests consistently decreased.
Her hair follicle drug test in August was still positive for methamphetamine and
marihuana, and, by September, was positive for 0.1 picograms per milligram
(pg/mg) of marihuana metabolite.
The trial court held the final termination hearing on three nonconsecutive
days—November 12, January 28, and February 9—and Riggs testified at each
setting. By the conclusion of the final hearing, M.A. Jr. was ten, and N.A. was eight
and they had been living with their relative, A.L., since August 2025. Riggs testified
that the children had a good relationship with A.L. and, though the transition was
difficult, “they seem[ed] to be doing well in school, and [Riggs] believe[d] that they
[were] happy.” A.L. was also willing to adopt the children if the parents’ rights were
terminated.
The Department sought to terminate each parent’s parental rights because its
ultimate goal was adoption, and “what [the children] want[ed] and need[ed] most of
all [was] stability and a home that they [didn’t] have to fear being taken out of again.”
A.L. testified that she believed it was in the children’s best interest to terminate the
parents’ parental rights “[t]o know that they have a stable home [and] are provided
safety, food, shelter, and . . . [were] not bouncing around from home to home.” A.L.
discussed the children’s routine, extracurricular activities, and, without further
explanation, mentioned that they attend weekly counseling sessions.
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The mother testified during the November hearing, and the father testified
during the January 2026 hearing after he had completed residential treatment. Both
parents recounted their struggles with addiction—the father’s began in 2019 with
weekend cocaine use, and the mother resumed using methamphetamine in January
2024 after seventeen years of sobriety.
Riggs testified that the Department’s “continuing concerns [were] the
[mother’s] use of mari[h]uana, the lack of stable income, the -- the non-compliance
with parts of her Service Plan and counseling and rehab.” The mother was employed
cleaning homes and provided Riggs with a screenshot of a payment she received.
Riggs testified that he “wouldn’t consider that to be proof of income or
employment,” but he never requested additional verification from the mother, nor
did he apprise her of her alleged non-compliance. The father worked, Riggs
believed, “for an auto shop and [was] paid in cash but [hadn’t] been able to
provide . . . any record of that.”
Reynolds and Vasquez opined that the mother had progressed and would
continue to do so. Reynolds observed that the mother was “working through some
traumas,” was “able to emotionally regulate,” and was “doing very well.” The
mother had post-traumatic stress disorder (PTSD) from domestic violence and
sexual trauma but had been successful in counseling. Reynolds and the mother
intended to continue counseling after the Department’s case was closed. Vasquez
had no concerns about the mother’s mental health, and Reynolds reiterated that the
mother loved her children, was “[a]bsolutely” committed to maintaining lifelong
sobriety, and that her children had been a motivating factor.
Reynolds and Vasquez confirmed that the mother applied for a housing
voucher through the United States Department of Housing and Urban Development
(HUD) and was still on the waitlist at the time of the final hearing. Vasquez
explained, “[I]t is a slow process right now because of HUD. . . . [N]ot many places
10
are available at the moment, but we are definitely trying to figure that out.” The
mother also applied for disability benefits and was employed at Little Caesars in
addition to cleaning homes.
The mother tested positive for marihuana in December 2025. In November
2025, the mother was prescribed low-THC cannabis under the Compassionate Use
Act to treat her PTSD, chronic pain, and a traumatic brain injury. See generally TEX.
HEALTH & SAFETY CODE ANN. §§ 487.001–.256 (West 2017 & Supp. 2025) (Texas
Compassionate-Use Act); TEX. OCC. CODE ANN. §§ 169.001–.006 (West 2022 &
Supp. 2025) (Authority to Prescribe Low-THC Cannabis to Certain Patients for
Compassionate Use); 37 TEX. ADMIN. CODE pt. 1 ch. 12 §§ 12.1–.61 (Tex. Dep’t of
Pub. Safety, Compassionate-Use/Low-THC Cannabis Program). She presented a
receipt for cannabis that she purchased on the same website that she accessed to
register for the program, which was shipped directly to her at the Noah Project.
Although using prescribed low-THC cannabis is generally prohibited, neither
Riggs nor the mother understood this illegality when they discussed her enrollment
in the Compassionate-Use Program. See OCC. § 169.001(3), (4). Riggs never told
the mother that her legal use of cannabis would be considered a continuing danger,
nor that she was prohibited from using it “because [he] didn’t know at the time that
that was the law.” On February 3, 2026, the mother was “exited” from the Noah
Project after an employee found “paraphernalia” in the mother’s belongings during
a random room check. The employee described the “paraphernalia” as an empty
container with residue that smelled like marihuana. According to Reynolds, by then
the mother had decided that “she was over it” and that she would not continue using
her cannabis prescription. Reynolds visited the website that the mother accessed to
purchase the cannabis and called it “misleading. . . . [I]t was discussed in court that
it was legal” for the mother to enroll in the program, and the website that the mother
accessed “was the first site that came up.”
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Riggs acknowledged the importance of speaking to the parents’ service
providers to determine whether the parents were making the necessary changes to
eliminate any continuing dangers and to provide a safe environment for their
children. Yet he had not reviewed the father’s counseling notes because he never
requested them. Moreover, he had not spoken to Reynolds since July 2025, and he
never contacted Vasquez or anyone else at Betty Hardwick to inquire about the
mother’s progress.
Riggs attended one of the mother’s counseling sessions soon after he was
assigned to the case but had no subsequent contact with Reynolds. Reynolds, a
former Department caseworker, testified that she routinely received and reviewed
family plans of service and removal affidavits from caseworkers of parents that she
treated. However, neither Reynolds nor Vasquez received any information from the
Department, which they said would have been helpful in treating the mother, and
“probably beneficial for this family as a whole.”
After every counseling session, Reynolds documented the mother’s progress
and her suggestions for the Department to review, uploaded her notes to a portal,
and sent them to Riggs. She testified that she receives a notification once the
recipient opens the portal to access her notes. Riggs testified that he reviewed
Reynolds’s counseling notes prior to the commencement of the final hearing, but
“had not received all of them.” He swore in a permanency report and during his
initial testimony that he e-mailed Reynolds a request for the mother’s counseling
notes. However, upon further questioning, he was unsure of the last time that he had
contacted Reynolds, which notes he had previously reviewed, and when he did so.
Riggs eventually admitted that he did “not review[] all of the notes that are in the
portal” before the final hearing. Reynolds refuted Riggs’s claims and testified that
she never received an e-mail request from Riggs, and it was not until after the first
day of the final hearing in November that Riggs accessed the portal to open the
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counseling notes she had previously sent. She further revealed that Riggs never
contacted her even after he accessed the portal.
Riggs also conceded that he had not fulfilled his obligation to meet in person
with each parent at least once a month. Consequently, Riggs was unaware that the
mother was still living at the Noah Project in November 2025 and that the father had
just begun inpatient treatment. He knew that the mother had applied for housing
assistance, but he was unfamiliar with the various HUD programs. He claimed that
the mother refused his offer to request Department funds for a deposit, but then
recalled that the mother had asked him to send her the paperwork to apply for that
funding, which he never sent her.
Riggs did not know where the father was living before his residential
treatment began. Even so, Riggs opposed the return of the children to the parents
without attempting to assess the safety of each parent’s living environment. He
likewise declared that neither parent demonstrated that they had made sufficient
behavioral changes to assuage the concerns of a continuing danger to the children.
With respect to the mother, Riggs testified:
We believe there is still continuing danger to the children. We
don’t see that sufficient behavior change has been made to assure us of
the safety of her home. . . . We are wanting to see, you know, continued
sobriety. We are wanting to see stability with regard to her ability to
provide for the children and the safety of the home.
Riggs then explained the purported continuing danger that prevented the
Department’s return of the children to the father:
We believe that [the father] has not yet fully overcome his issues
with addiction. We are hopeful that [inpatient treatment,] where he is
now[,] will be able to provide that for him. But as of today, we don’t
feel like that he has made that -- he has been successful in that yet.
Riggs repeatedly admitted that he failed to communicate consistently with the
parents and did not “make every effort that [he] needed to make.” He stated that the
13
mother had “been responsive and mostly cooperative,” and that her drug levels had
“consistently gone down” since the beginning of the case. He apologized to the
mother for his lack of communication and testified that his notes and the reports that
he filed with the trial court were “not as accurate as [he] would like them to be.”
Riggs also professed that his communication with the father was “not sufficient and
less than what was required of [him] as a caseworker.”
Rhea Rodriguez, the executive director at Treehouse Safe Exchange, testified
that since the outset of the case, the mother had “been consistent,” was “very happy
and positive,” and “[s]eem[ed] to have learned a lot within herself.” Rodriguez
attributed the mother’s improvement in her parenting capabilities to her sobriety and
participation in services. Visitation supervisor William Hampton, who observed the
most interactions between the children and the parents, testified that the mother was
“staying clean, and she love[d] to see her boys.” He noticed over time that the
mother was “happier,” “ha[d] more energy,” was “attentive,” and brought food for
the children rather than relying on the pantry at Treehouse. Hampton described the
mother as interactive during her visits with the children, was “aware of . . . their
different needs,” and was able to meet those needs. Neither Hampton nor Rodriguez
had any concerns regarding the mother’s ability to be an appropriate, safe, and stable
parent to the children. Visits between the father and the children had also gone well
and there was a strong bond between the children and the father; the father was safe
and appropriate, played with the children, brought them food, and was “[v]ery
interactive.”
At the conclusion of the hearing, the mother re-urged her request for the
monitored return of the children, or the appointment of the Department as permanent
managing conservator while she continued to demonstrate that she could maintain
sobriety. The father also asked the trial court to deny the Department’s petition to
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terminate his parental rights and requested more time to continue receiving services
with the hope that his children could be returned to him one day.
In its letter ruling, the trial court specifically found that “evidence of improved
conduct, especially of short duration, . . . does not negate the parents’ long and
continuing history of irresponsible choices that endangered their children, including
but not limited to years of illegal drug use.” The trial court also found “that not all
portions of the parents’ testimony was credible.” The trial court acknowledged in a
footnote that “[a]lthough the Department’s efforts were not ideal during some
portions of this case, the Department’s efforts considered as a whole were reasonable
efforts to return the children.”
The trial court terminated each parent’s parental rights and found termination
to be in the best interest of the children. See FAM. § 161.001(b)(1)(D), (E), (b)(2).
This appeal followed.
III. Endangerment
In the father’s second issue, he challenges the trial court’s findings that he
endangered the children. See FAM. § 161.001(b)(1)(D), (E). Because of our
resolution of the father’s third issue, we need only address the legal sufficiency
challenge to the trial court’s findings under Section 161.001(b)(1), which could
potentially result in a rendition rather than a remand. See J.F.C., 96 S.W.3d at 266;
In re T.M., No. 11-25-00273-CV, 2026 WL 770620, at *7 (Tex. App.—Eastland
Mar. 19, 2026, no pet.) (mem. op.).
The statutory endangerment grounds require clear and convincing proof that
the parent has: “(D) knowingly placed or knowingly allowed the child[ren] to remain
in conditions or surroundings which endanger the physical or emotional well-being
of the child[ren],” or “(E) engaged in conduct or knowingly placed the child[ren]
with persons who engaged in conduct which endangers the physical or emotional
well-being of the child[ren].” FAM. § 161.001(b)(1)(D), (E); In re S.M.R., 434
15
S.W.3d 576, 585 (Tex. 2014). “[E]ndangerment encompasses a larger array of
conduct that ‘expose[s a child] to loss or injury’ or ‘jeopardize[s]’ the child.” In re
R.R.A., 687 S.W.3d 269, 277 (Tex. 2024) (quoting Tex. Dep’t of Human Servs. v.
Boyd, 727 S.W.2d 531, 533 (Tex. 1987)). The term means “more than a threat of
metaphysical injury or potential ill effects of a less-than-ideal family environment,”
E.N.C., 384 S.W.3d at 803, but “does not require actual harm.” R.R.A., 687 S.W.3d
at 277 (citing Boyd, 727 S.W.2d at 533).
To terminate a parent’s rights based on endangerment under subsections (D)
or (E), the “parent’s endangering conduct need not ‘be directed at the child,’” nor
must “the child actually suffer[] injury.” R.R.A., 687 S.W.3d at 277 (quoting Boyd,
727 S.W.2d at 533); In re C.E., 687 S.W.3d 304, 310 (Tex. 2024). “[T]ermination
under [subsection] (D) requires that the child’s environment is a source of
endangerment, and the parent’s conduct may create that dangerous environment.”
C.E., 687 S.W.3d at 310. For instance, “[a] parent’s drug use, violence, or other
abuse may make the child’s environment endangering to the child.” In re J.S., 675
S.W.3d 120, 128 (Tex. App.—Dallas 2023, no pet.). “A parent acts ‘knowingly’
when the parent is aware that the environment creates a potential danger to the child
but the parent disregards that risk.” Id. Because conditions or surroundings cannot
endanger a child unless the child is exposed to them, the relevant time frame for
evaluating the applicability of subsection (D) is before the child’s removal. J.W.,
645 S.W.3d at 749.
In contrast, endangerment under subsection (E) focuses on the parent’s
conduct, and whether the endangerment of the child’s well-being was the direct
result of the parent’s actions, omissions, or failures to act. J.S., 687 S.W.3d at 550.
Termination under subsection (E) must be based on more than a single act or
omission; instead, a voluntary, deliberate, and conscious course of conduct by the
parent is required. Id.; In re D.T., 34 S.W.3d 625, 634 (Tex. App.—Fort Worth
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2000, pet. denied). “A factfinder may infer endangerment from ‘a course of conduct’
that presents substantial risks to the child’s physical or emotional well-being.”
R.R.A., 687 S.W.3d at 277. Further, a parent’s actions prior to and after the child’s
removal may show an endangering course of conduct. See J.S., 687 S.W.3d at 550
(“[E]ndangering conduct may include the parent’s actions before the child’s birth
and may relate to the parent’s actions while the parent had possession of other
children.”). “Even evidence of criminal conduct, convictions, and imprisonment
prior to the birth of a child will support a finding that a parent engaged in a course
of conduct that endangered the child’s well-being.” In re A.J.M., 375 S.W.3d 599,
606 (Tex. App.—Fort Worth 2012, pet. denied); Walker v. Tex. Dep’t of Fam. &
Protective Servs., 312 S.W.3d 608, 617 (Tex. App.—Houston [1st Dist.] 2009, pet.
denied) (Illegal drug use and offenses that occurred before the child’s birth may be
considered as part of a course of conduct that endangers a child.).
The father began using cocaine around 2019 and used methamphetamine
almost daily for a year or two before the final termination hearing commenced. His
drug use continued for nearly a year after the children were removed from his care.
“[A] parent’s decision to engage in illegal drug use during the pendency of a
termination suit, when the parent is at risk of losing a child, may support a finding
that the parent engaged in conduct that endangered the child’s physical or emotional
well-being.” J.S., 687 S.W.3d at 551 (quoting In re A.M., 495 S.W.3d 573, 580
(Tex. App.—Houston [1st Dist.] 2016, pet. denied)).
However, “illegal drug use alone may not be sufficient to show
endangerment.” R.R.A., 687 S.W.3d at 278. The evidence must show that a parent’s
“pattern of drug use accompanied by circumstances that indicate[d] related dangers
to the child” created “a substantial risk of harm.” Id. Here, the father expressed
concerns regarding the mother’s mental health and the children’s safety if they were
left in her care. He also knew that the mother had resumed using methamphetamine
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after her years of sobriety. The father refused to sign a safety plan, but he agreed
not to permit unsupervised contact between the children and the mother. Despite the
father’s concerns and verbal agreement, he left the children with the mother,
unsupervised, because he chose to continue using methamphetamine.
Viewing the evidence in the light most favorable to the trial court’s finding
under subsection (E), we hold that a rational trier of fact could have formed a firm
conviction or belief that the father “engaged in conduct or knowingly placed the
child[ren] with persons who engaged in conduct which endanger[ed] the physical or
emotional well-being of the child[ren].” FAM. § 161.001(b)(1)(E); In re J.P.B., 180
S.W.3d 570, 573 (Tex. 2005). Because only one statutory ground is necessary to
support a termination finding, we need not address the father’s complaint insofar as
it relates to subsection (D). See FAM. § 161.001(b)(1); In re N.G., 577 S.W.3d 230,
234–35 (Tex. 2019); see also TEX. R. APP. P. 47.1.
Accordingly, we overrule the father’s second issue.
IV. The Best Interest of the Children
In the mother’s first issue and the father’s third issue, they challenge the legal
and factual sufficiency of the evidence to support the trial court’s findings that
termination of that parent’s parental rights is in the best interest of the children.
“‘[B]est interest’ is a term of art encompassing a much broader, facts-and-
circumstances based evaluation that is accorded significant discretion.” In re Lee,
411 S.W.3d 445, 460 (Tex. 2013) (quoting Holley, 544 S.W.2d at 371–72). Because
the trial court is the sole judge of the witnesses’ credibility, we generally do not
disturb the factfinder’s determinations so long as those determinations are not
unreasonable. J.F.-G., 627 S.W.3d at 312; J.P.B., 180 S.W.3d at 573.
“The strong presumption is that termination is not in a child’s best interest, so
a parental-termination order must always be a last resort and never a first impulse.”
H.S., 2026 WL 1614496, at *1. Evidence of each Holley factor is not required to
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support a best interest finding. C.H., 89 S.W.3d at 27–28; J.S., 687 S.W.3d at 547–
48; In re S.R., 452 S.W.3d 351, 366 (Tex. App.—Houston [14th Dist.] 2014, pet.
denied). However, “[t]he presence of scant evidence relevant to each factor will
generally not support a finding that termination of parental rights [is] in the child’s
best interest.” In re D.L.W.W., 617 S.W.3d 64, 82 (Tex. App.—Houston [1st Dist.]
2020, no pet.). Conjecture, proof by only a preponderance of the evidence, or a lack
of evidence is not enough for a reasonable factfinder to form a firm belief or
conviction that termination of a parent’s parental rights is the best interest of the
child. See E.N.C., 384 S.W.3d at 808, 810; In re M.A.J., 612 S.W.3d 398, 410 (Tex.
App.—Houston [1st Dist.] 2020, pet. denied); T.M., 2026 WL 770620, at *11.
We first observe that the trial court, as the factfinder, permissibly disregarded
portions of the parents’ testimony that it found not to be credible. See In re H.R.M.,
209 S.W.3d 105, 109 (Tex. 2006). The remaining testimony presented to it during
the final hearing was from Riggs, A.L., two Department investigators, Officer
George Spindler, visitation supervisors Hampton and Rodriguez, Reynolds,
Vasquez, and Kaylee Jones, the Noah Project employee who searched the mother’s
room.
As set forth above, Riggs recited or otherwise agreed to the legally operative
words and phrases that supported the trial court’s termination findings—he attested
to developing service plans, sending referrals, offering transportation and financial
assistance, and scheduling parent-child visitations. He parroted the Department’s
recommendation based on his view of each parent’s respective failures to
(1) overcome “issues with addiction,” (2) demonstrate the ability to maintain
sobriety, and (3) provide the children with a safe and stable home environment.
Considered in isolation and untested by a meani